SBM-2 Interests and views of stakeholders

Key stakeholder groups in the Enea Group are: employees, customers, investors, local communities, business partners and suppliers and workers in the value chain. In the course of its operational and strategic activities, the Enea Group also identifies public administration bodies, industry organizations and non-governmental organizations (NGOs) as stakeholders.

The Group identifies the interests of its key stakeholders using a formalized and systematic procedure based on corporate documents such as the Stakeholder Engagement Policy, the Principles of Social Engagement, and the Social Engagement Policy adopted in December 2025. This process is an integral element of sustainability management.

Employees

The Enea Group recognizes its employees as one of the key stakeholder groups. Engagement with this group is permanent and is based on internal dialog mechanisms and operational structures. Employees are involved in the process of identifying local needs and designing community initiatives, through:

  • direct collaboration with representatives of subsidiaries responsible for CSR/ESG;
  • consultations regarding social projects and internal coordination within the ESG Division, including updates to the double materiality assessment;
  • an internal reporting channel enabling the reporting of information on local needs and potential partners.

The purpose of these activities is to effectively identify social needs in our operational environment, identify potential risks and opportunities in the social area (S1), and use operational knowledge of our employees. The outcomes of this engagement are used in decision-making processes, annual planning and non-financial reporting.

The Enea Group Development Strategy to 2035 and the Enea Group Sustainability Strategy to 2035 are affected by the interests, views and rights of employees. During the work on the Development Strategy, the Enea Group’s parent company, Enea S.A., included the trade unions in the consultations. Representatives of the trade unions presented postulates for taking their interests into consideration in the Development Strategy. Some postulates of the trade unions were similar to provisions of the Strategy, whereas the remaining ones were reflected in two new strategic directions (1.6.1 Cooperation with the Local Government Units [LGU] for restoring jobs in regions related to coal assets and 1.6.2 Management of competences of present employees within energy transition of the Enea Group). The entire business model of the Enea Group is not consulted with the employees.

The Group companies make efforts to take into account the employees’ interests, views and rights during annual negotiations of working conditions and remuneration with the trade unions. Company management boards or their representatives also conduct regular direct dialog with trade union representatives by meeting periodically to discuss the situation of the company and its employees in order to safeguard their interests. Furthermore, the trade unions maintain regular correspondence with the companies’ management boards, in which numerous issues connected with employees’ interests are touched on and explained. In Internal Collective Bargaining Agreements, rules of negotiating and interpreting provisions of the agreements are defined, including first of all working and remuneration conditions. In addition, the Management Board of LW Bogdanka established a Team for negotiations with the trade unions operating in the company, whose task is to amend the wording of the Internal Collective Bargaining Agreement and to clarify its disputed provisions. Everyone employed in LW Bogdanka may request an amendment to an ICBA or its interpretation, which allows the employees to influence the strategy and business model developed in the company.

Customers

Customer relations are based on satisfaction surveys and the analysis of customer feedback. This enables the identification of energy security expectations and allows for better alignment of offerings. Data from customers is forwarded to senior management and used in the planning and continuous improvement processes. In response to customer expectations, service quality improvements have been integrated into the Enea Group Development Strategy to 2035 and the Enea Group Sustainability Strategy to 2035.

The interests, views and rights of consumers or end-users, including respect for their human rights, affect the Group’s strategy and business model. In terms of customer relations and the security and reliability of energy supplies, the Development Strategy has adopted objectives such as ensuring a continuous supply of electricity with appropriate quality parameters and adapting the distribution network to operate in a decentralized power system.

Moreover, all activities of the Group affecting consumers or end-users are conducted in accordance with generally applicable laws and market standards, such as the Compendium of Electricity Consumer Rights and the Best Practices of Electricity and Gaseous Fuel Suppliers. As regards personal data protection, the Group has a Personal Data Protection Policy in place that complies with the Personal Data Protection Regulation, and the parent company aims to reduce data protection incidents to a minimum. When reacting to incidents related to any breaches of personal data protection, Enea S.A. continuously inspects the implemented procedures and amends the adopted solutions as necessary.

Investors

The Enea Group, through its Investor Relations Office, maintains an ongoing dialog with the capital market. It is based on current and periodic reports, earnings conferences, ESPI/EBI communications, and General Meetings of Shareholders. Chapter 10.3 of the Management Board Report on the Activity of Enea S.A. and the Enea Group in 2025 provides a detailed description of investor relations.

The purpose of these activities is to ensure transparency and alignment with the Group’s strategy, whose core assumptions, such as increasing the company value, are consistent with investor expectations.

Local communities

The Enea Group cooperates with local governments and conducts social consultations when implementing new investments. It monitors social needs and sentiments in the areas where key generation and mining assets are located, which enables ongoing assessment of its operations’ impact on the environment.

Incorporating community feedback is regarded as a prerequisite for maintaining the so-called “social license to operate.” This is particularly important in mining regions, where the voice of the community determines the approach to a just transition. The Development Strategy envisages responsible support for regional transition processes, including joint initiatives with local government units geared toward the development of industrial areas.

The views, interests and rights of local communities affect the strategy and business model of some Enea Group companies. This applies to companies managing the district heating network (Enea Ciepło, MEC Piła, PEC Oborniki, Enea Elektrownia Połaniec), the development of which is being ensured in consultation with local communities. The Sustainability Strategy also contains objectives related to Enea Group’s social engagement to supports local communities.

Business partners and suppliers

This stakeholder group is covered by the Enea Group Procurement Policy applies. Cooperation with suppliers is conducted through tender procedures and execution of ongoing tasks. In 2025, a contractor review procedure was adopted as part of the Third-Party Risk Management (TPRM) system. The interests of this group are incorporated through dialog during procurement processes and contract execution, the formulation of references, and double materiality assessments, in which respondents identified their priority sustainability aspects.

Workers in the value chain

The Enea Group did not directly engage workers in the value chain in the double materiality analysis process; however, to account for their interests regarding labor rights, it sets specific requirements for suppliers and business partners.

The Sustainability Strategy includes objectives related to a sustainable supply chain and the verification of key counterparties, which support the interests and human rights of individuals performing work within the Enea Group value chain.

Public administration and state authorities

The Enea Group maintains an ongoing dialog with administrative bodies such as ERO (Energy Regulatory Office), UOKiK (Office of Competition and Consumer Protection), and UODO (Personal Data Protection Office). These interactions have a direct impact on how the company operates, from energy pricing to data protection systems. The opinions from state administration representatives are considered in the materiality assessment process, and the organization continuously adjusts its operations to regulatory requirements.

Industry Organizations and NGOs

The Enea Group participates in the work of industry organizations influencing the directions of development of the energy sector. Additionally, the Enea Group cooperates with non-governmental organizations (NGOs) to implement joint social projects related to, among others, education, health, and sports. The opinions of these organizations are used to plan the directions of social initiatives.

Impact on strategy and business model

The opinions and interests of key stakeholders are integrated directly in the Group’s management processes and taken into account in risk management processes at the Group level, including:

  • the double materiality assessment process;
  • the identification of social risks and opportunities;
  • the updating of the ESG Risk Map.

During the reporting period, the Group did not change its corporate strategy or business model as a direct result of dialog with stakeholders.

Conclusions from the stakeholder dialog process are incorporated into planning processes and strategic reviews; they determine the allocation of resources over the medium and long term. The Group’s management and supervisory bodies are regularly informed of stakeholder views and interests, which ensures effective oversight of sustainability-related impacts. Synthetic information on the results of stakeholder dialog is presented by ESG functions to the Management Board and the Supervisory Board on an annual and quarterly basis. Conclusions from stakeholders also forms the basis for recommendations to the Management Board, which are used to make decisions on strategic directions and to assess alignment with Group policies. Stakeholder views are also a fixed element of periodic strategy implementation reviews and the monitoring of non-financial risks performed by the Enea Group’s top management bodies.

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